The next reporting period - the key points and best practices

The third reporting period starts next week. Affected companies must again prepare and submit a CBAM report on imported goods in July. goods in July. This time on their goods imported in the second quarter 2024 imported goods.

We are still in the so-called introductory phase of the transition phase. This will remain in place until the end of July and affected companies with some relief.

Preparation of the CBAM report

For the preparation of this CBAM report for the 2nd quarter of 2024, which must be submitted by the end of next month at the latest, the standard the standard values can still be used in full. It is still not necessary not yet necessary to specify a manufacturer of the imported goods. manufacturer of the imported goods. Companies should have familiarized themselves with this type of simplified companies should have familiarized themselves with this type of simplified reporting by now. The necessary data should be available. The internal processes and structures structures should be in place and the preparation of the the necessary customs data should not present companies with major difficulties. present companies with major difficulties.

Possibility of modification

However, the introductory phase also brought a second significant facilitation, which many -- especially larger -- companies have made use of. have made use of. Companies with a reporting obligation have until the end of the the end of the introductory phase at the end of July to amend and complete their to amend and complete the reports they have already submitted. This deadline, which coincides with the submission of the CBAM report for the second quarter should be kept in mind as a matter of urgency. Companies should prepare the data now at the latest and correction, if necessary, with the preparation of the regularly due CBAM report is due.

Control of companies subject to CBAM

The German Emissions Trading Authority has confirmed that a companies subject to CBAM have so far been checked almost exclusively only with regard to the submission of a CBAM report. A content of the reports submitted, as these are largely largely waived, as these are still being processed by the companies. by the companies. The content review will therefore begin in the third quarter of 2024.

Best practices

When preparing the CBAM report that is now due, companies should the simplifications of the introductory phase. This reduces the susceptibility to errors in the report. On the one hand, it has been shown that that actual emission values that have already been submitted are unfortunately too too good to be true. It is not advisable to use these for the report, provided you can still use standard values without hesitation. default values can be used without hesitation.

On the other hand, companies should also refrain from stating the manufacturer's manufacturer. This is because it has been shown that there is still confusion in the assignment of one's own supplier to the technical terms “operators” and ‘installations’. At the same time, it is often unclear whether a supplier is just a middleman or the producer of the goods. a distributor or the producer of the goods. These difficulties can easily be avoided by omitting the indication in the be easily avoided during the introductory phase.

It is also conceivable that the DEHSt will initially be interested in checking reports that have already been prepared on the basis of actual emissions data. on the basis of actual emissions data. This means that not directly in the view of the authorities.

CBAM support

If you want to set up your company now for the long term after the introduction phase, please get in touch with me directly (helge@kolum.earth). We will be happy to support you!
Best regards

Helge Wieggrefe